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Oakwood Laboratories LLC v. Thanoo

In 2017, Oakwood Laboratories, L.L.C. (“Oakwood”) sued its former Vice President of Product Development, Dr. Bagavathikanun Thanoo, as well as Dr. Thanoo’s current employer, Aurobindo Pharma U.S.A., Inc. (“Aurobindo USA”), the parent of that company, Aurobindo Pharma Ltd. (“Aurobindo”), and a sister company, AuroMedics Pharma LLC (“AuroMedics”) (collectively, “the Defendants”), asserting claims of trade secret misappropriation, breach of contract, and tortious interference with contractual relations. More than two years and four iterations of its complaint later, Oakwood was unable to get past the pleading stage of litigation. The District Court dismissed each version of the complaint for failure to state a claim.

After each dismissal, Oakwood endeavored to address the problems the District Court perceived. Those efforts culminated in a Third Amended Complaint (generally referenced herein simply as the “Complaint”) so factually detailed that, on appeal, we conclude it easily meets the pleading requirements of the Federal Rules of Civil Procedure and pertinent substantive law. We will, therefore, vacate the District Court’s dismissal and remand the case for further proceedings. In doing so, we endeavor to clarify the requirements for pleading a trade secret misappropriation claim under the Defend Trade Secrets Act, 18 U.S.C. § 1836(b) (“DTSA”).

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